The Impact of Junk Science on R&D: A Review of the 'Dirty Dozen'

By: David C. Steinberg, Steinberg & Associates

Posted: September 29, 2010, from the October 2010 issue of Cosmetics & Toiletries.

Last spring, the David Suzuki Foundation, an environment conservation group based in Vancouver, published a report online describing what it called the “dirty dozen” cosmetic ingredients consumers should avoid.¹ The group went so far as to provide a downloadable pocket guide of the 12 ingredients for consumers to use when they shop to avoid purchasing products containing these ingredients. Normally this column would not cover the faulty and misleading junk science of non-governmental organizations (NGOs); however, with current political activity in the US Congress, i.e. the introduction of the Safe Cosmetics Act of 2010, the industry should be aware of what it is facing.

In addition, marketing is well aware of consumers’ perceptions of ingredients, which in turn are passed on to R&D with the directive to omit those that are negatively viewed for “free-from” product claims. Thus, the information presented here supports both R&D and marketing by providing the solid facts behind these 12 ingredients; but since consumer perception ultimately determines success, if this effort to present sound science is futile, it may simply offer R&D a forecast of the ingredients that eventually will require replacing.

The David Suzuki Foundation is a registered charitable organization in the United States and Canada that was established in 1990 to deal with environmental issues. Due to its well-respected status, this author was surprised to see such faulty science reported by this group, as each individual ingredient description below illustrates. Following are the 12 ingredients identified, including comments from the foundation website, with additional facts about each that should have been included. Also included is the frequency of use for each ingredient, based on the US Food and Drug Administration’s (FDA) database of some 36,811 registered formulations.

BHA or BHT

According to the foundation report: Butylated hydroxyanisole (BHA) and butylated hydroxytoluene (BHT) are used mainly in moisturizers and makeup as antioxidants and preservatives. They are also a hidden ingredient in some fragrances. BHA is toxic to the immune system and the International Agency for Research on Cancer classifies it as a possible human carcinogen. Studies suggest that BHT may be toxic to the skin, lungs, liver and immune system. Both chemicals can cause allergic reactions, are suspected of interfering with hormone function (endocrine disruption), and may promote tumor growth. They also have the potential to bio-accumulate in aquatic species.

Facts: While BHA and BHT are antioxidants, they are used primarily in foods where they are generally recognized as safe (GRAS) by the FDA at up to 0.02% fat content.^{2, 3} The Personal Care Products Council Cosmetic Ingredient Review (CIR) found the materials to be safe as cosmetic ingredients; however, BHA is listed in California’s Proposition 65 legislation, so its use in cosmetics is declining. Based on the FDA database, BHA is currently included in 905 registered formulations while BHT is in 4,890.